Considered Assessment Appeal Application Nos. 16-25, 17-101, 18-91 and 19-044 (Real Property Only) filed by Walgreen Company, the facility which is the subject of all the Applicant's Appeals is a warehouse located at 2170 East Main Street in Woodland, California. John Origer and Rob Cooney, agents for the applicant, appeared. Agents, Chief Deputy Assessor George Galang and Principal Appraiser Patricia Sanchez addressed the Board. The Clerk confirmed that a deposit of $309 for findings of fact had been paid.

After hearing from the parties that the Applicant was asserting a general use and that the Assessor was asserting a special use, and with agreement of the parties, the Board bifurcated the two issues.

The Board called the parties attention to two prior appeals taken by Applicant on the same subject facility and suggested that application of the doctrine of res judicata may well be applicable in the issue of general use or special use facility. Applicant’s representatives indicated that they had not seen nor reviewed these findings and were not aware of this being an issue. The Board provided to both parties copies of Yolo County Assessment Appeals Board FINDINGS, CONCLUSION AND ORDER filed January 24, 2001 in the Application of Walgreen Company for this same subject facility in Application 99-67 and also Yolo County Assessment Appeals Board FINDINGS, CONCLUSION AND ORDER filed November 16, 2011 in the Application of Walgreen Company for this same subject facility in Application 09-1151. The Board then called a recess to give the parties an opportunity to review the findings. At the conclusion of the recess the Applicant asserted that the doctrine of res judicata does not apply to proceedings before a County Board of Equalization and offered two letters by James W. Williams, Esq., Tax Counsel to the State Board of Equalization, one dated October 10, 1991, and the other dated April 30, 1993, both advising that the doctrine of res judicata does not apply in assessment appeals. In response the Board took testimony and heard argument on the issue of special or general use and retired to closed session to consider the matter.

Minute Order No. 22-33: Moved that at the valuation dates for these proceedings the subject property is to be valued as a special purpose facility and not a general use warehouse in that its wall height is 45 and 56 feet, not the 28 to 30 feet of a general purpose warehouse, it is of steel I-beam and concrete block construction, not the tilt-up concrete construction of a general purpose warehouse, unlike a general use warehouse it is heated and air conditioned, has a special racking and conveyer system initially state of the art but no longer so considered by Applicant, extra high forklifts designed to accommodate the higher walls and racking, a fine mesh steel chain link vault for pharmaceuticals no longer locked and now used only for general storage (the pharmaceutical function having been outsourced by Applicant), a large area specially designed for regional distribution staff consisting of offices, conference rooms, and training facilities, forklift repair facility for extra high forklifts, truck maintenance and fueling center, specially reinforced truck parking, solar panels, and a large water tank and fire suppression system.

Applicant requested a continuance inasmuch as it was not aware of the potential characterization of the property as a special use facility. After the Board considered the request in closed session, they took the following action in open session:

Minute Order No. 22-34: Granted Applicant’s request for Continuance to August 10, 2022 at 9:00 a.m. (a date agreed to by all parties) for the purpose of valuation of the subject facility as a special use warehouse.